Lessons From FTC 2018 Privacy and Data Security Update: Hearings, Reports and 2019 Predictions

In its most recent Privacy and Security Update (Update), the FTC provided information on best privacy and data security measures for companies with its recap of its 2018 enforcement actions, workshops and other guidance. In this third and final article in our series on the Update, we explore takeaways from the FTC’s hearings and reports, and forecast what to expect in the remainder of 2019, such as the FTC’s much-anticipated settlement with Facebook over privacy violations that could amount to an unprecedented fine of up to $5 billion. In part two, legal experts distilled valuable lessons from enforcement in financial privacy and COPPA cases, and discussed the agency’s international focus. In part one, we examined enforcement highlights from general privacy and data security cases and discussed what these actions tell us about steps companies can take to comply with applicable laws and steer clear of the FTC’s reach. See also “Lessons and Trends From FTC’s 2017 Privacy and Data Security Update: Enforcement Actions (Part One of Two)” (Jan. 31, 2018); Part Two (Feb. 14, 2018).

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